Case Digest (G.R. No. 59791)
Facts:
Manila Electric Company v. The Honorable Gregorio G. Pineda, G.R. No. L-59791, February 13, 1992, Supreme Court First Division, Medialdea, J., writing for the Court.Petitioner Manila Electric Company (MERALCO) filed an eminent domain complaint on October 29, 1974 in the Court of First Instance (CFI) of Rizal, Branch XXII, Pasig, seeking portions of lands in Barrio Malaya, Pililla, Rizal for a 230 KV transmission line against forty-two defendants, including private respondents Teofilo Arayon, Sr., Gil de Guzman, Lucito Santiago and Teresa Bautista, who owned the affected parcels in fee simple. MERALCO alleged attempts to negotiate and offers to pay compensation but asserted no agreement was reached.
Private respondents challenged MERALCO’s legal existence and the claimed area in motions filed late 1974 and early 1975 and sought contempt remedies alleging MERALCO’s corporate existence expired. Despite those motions, the trial court issued an order on January 13, 1975 authorizing MERALCO to enter the property. On July 13, 1976 private respondents moved to withdraw funds from MERALCO’s deposited amount, claiming entitlement at P40.00 per square meter; that motion was denied on September 3, 1976.
Branch XXII became vacant and Judge Gregorio G. Pineda (respondent) acted on the case. MERALCO sold its power plants and transmission lines, including the disputed lines, to the National Power Corporation (Napocor) on October 30, 1979. The court appointed commissioners on February 11, 1980, but MERALCO’s June 5, 1980 motion to dismiss—asserting loss of interest due to the Napocor sale—suspended the commissioners’ work.
Private respondents renewed motions for payment: on June 9, 1981 and again on December 15, 1981 they sought withdrawal of sums from MERALCO’s deposit. The respondent court issued orders dated December 4, 1981 and December 21, 1981 permitting partial withdrawals (P20,400.00 and P90,125.50 respectively) “without prejudice to the just compensation that may be proved in the final adjudication.” On January 8, 1982 private respondents moved for further payment; MERALCO filed a motion for reconsideration (Jan. 12, 1982) and charged falsification and sought contempt.
On February 9, 1982 Judge Pineda denied MERALCO’s motion for reconsideration and motions for contempt but went further to “adjudge[] in favor of defendants … the fair market value of their property taken by MERALCO at P40.00 per square meter for a total of P389,720.00,” awarding interest and attorney’s fees, and ordering payment net of prior withdrawals. The court explained that, while it might dispense with commissioners and formulate its own opinion, any such estimate must rest on competent evidence.
Afterward, on March 22, 1982 the respondent court granted private respondents’ motion for execution pending appeal and ordered MERALCO to deposit P52,600,000.00 (an amount computed from the Napocor consideration). MERALCO sought relief from this Court by petition for preliminary injunction; the Supreme Court issued a temporary restraining order enjoining enforcement of the March 22 order while the petition was pending.
MERALCO assailed the trial court’s determination of just compensation without formal hearing before commissioner...(Subscriber-Only)
Issues:
- Did the respondent court violate MERALCO’s constitutional right to due process by determining and ordering payment of just compensation without the assistance of a Board of Commissioners?
- Were the trial court’s December 4, 1981 and December 21, 1981 orders allowing private respondents to withdraw portions of MERALCO’s deposit proper?
- Should the National Power Corporation (Napocor) be impleaded (or substituted) as party plaintif...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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